RS-14-194, Response to Request for Additional Information Regarding Fukushima Lessons Learned - Flood Hazard Reevaluation Report

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Response to Request for Additional Information Regarding Fukushima Lessons Learned - Flood Hazard Reevaluation Report
ML14293A599
Person / Time
Site: Byron, Braidwood, Clinton, LaSalle  Constellation icon.png
Issue date: 07/14/2014
From: Kaegi G
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-14-194
Download: ML14293A599 (16)


Text

A Exeton Generation, 10 CFR 50.54(f)

RS-14-194 July 14, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-1 1 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Response to Request for Additional Information Regarding Fukushima Lessons Learned - Flood Hazard Reevaluation Report

References:

1. Exelon Generation Company, LLC Letter to USNRC, Response to March 12, 2012 Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 2, Flooding Hazard Reevaluation Report, dated March 12, 2014 (RS-14-052 Braidwood)
2. Exelon Generation Company, LLC Letter to USNRC, Response to March 12, 2012 Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 2, Flooding Hazard Reevaluation Report, dated March 12, 2014 (RS-14-053 Byron)
3. Exelon Generation Company, LLC Letter to USNRC, Response to March 12, 2012 Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 2, Flooding Hazard Reevaluation Report, dated March 12, 2014 (RS-14-054 Clinton)
4. Exelon Generation Company, LLC Letter to USNRC, Response to March 12, 2012 Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 2, Flooding Hazard Reevaluation Report, dated March 12, 2014 (RS-14-055 LaSalle)

U.S. Nuclear Regulatory Commission Response to Request for Additional Information (Flooding Hazard Reevaluation Report)

July 14, 2014 Page 2

5. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012
6. NRC Email Request for Additional Information (RAI) Regarding Braidwood, Byron, Clinton, and LaSalle Stations Fukushima Lessons Leamed - Flood Hazard Reevaluation Report, dated June 18, 2014 In References 1 through 4, Exelon Generation Company, LLC (EGC) provided the Flooding Hazard Reevaluation Reports for Braidwood Station, Byron Station, Clinton Power Station, and LaSalle County Station, respectively, in response to the March 12, 2012 Request for Information , Recommendation 2.1, Flooding, Required Response 2, (Reference 5).

The purpose of this letter is to provide the response to the NRC request for additional information (RAI) (Reference 6). Enclosures 1 through 4 to this letter provide each station's response to the information request, and identify the specific folder location on Enclosure 5 containing the requested information. Enclosure 5 to this letter provides electronic information files requested by Reference 6.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Ron Gaston at (630) 657-3359.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 140' day of July 2014.

Respectfully submitted, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosures:

1. Braidwood Response to NRC Request for Additional Information Regarding FHRR
2. Byron Response to NRC Request for Additional Information Regarding FHRR
3. Clinton Response to NRC Request for Additional Information Regarding FHRR
4. LaSalle Response to NRC Request for Additional Information Regarding FHRR
5. Hard Drive With Electronic Information

U.S. Nuclear Regulatory Commission Response to Request for Additional Information (Flooding Hazard Reevaluation Report)

July 14, 2014 Page 3 cc: Director, Office of Nuclear Reactor Regulation (w/o Enclosure 5)

NRC Regional Administrator - Region III (w/o Enclosure 5)

NRC Senior Resident Inspector - Braidwood Station, Units 1 and 2 (w/o Enclosure 5)

NRC Senior Resident Inspector - Byron Station, Units 1 and 2 (w/o Enclosure 5)

NRC Senior Resident Inspector - Clinton Power Station, Unit 1 (w/o Enclosure 5)

NRC Senior Resident Inspector -LaSalle County Station, Units 1 and 2 (w/o Enclosure 5)

NRC Project Manager, NRA - Braidwood Station, Units 1 and 2 (w/o Enclosure 5)

NRC Project Manager, NRR - Byron Station, Units 1 and 2 (w/o Enclosure 5)

NRC Project Manager, NRR - Clinton Power Station, Unit 1 (w/o Enclosure 5)

NRC Project Manager, NRR - LaSalle County Station, Units 1 and 2 (w/o Enclosure 5)

Mr. Blake A. Purrnell, NRR/DORL/LPL3-2, NRC (with Enclosure 5)

Mr. Joel S. Wiebe, NRR/DORL/LPL3-2, NRC (with Enclosure 5)

Illinois Emergency Management Agency - Division of Nuclear Safety (w/o Enclosure 5)

Enclosure 1 Braidwood Station, Units 1 and 2 Response to NRC Request for Additional Information Regarding FHRR (2 pages)

Response to Request for Additional Information (Flood Hazard Reevaluation Report)

Page 1 of 2 Braidwood Station

a. Input and output files associated with FLO-2D modeling for the Local Intense Precipitation analysis. With regards to the output files, include any files that provide depths, velocities, and water surface elevations (e.g.

SUMMARY

.out, DEPTH.out).

Response: The requested FLO-2D input and output files are provided in Enclosure 5, "Enclosure 1-(Braidwood)" folder under sub-folder "FLO-2D" of the enclosed electronic files.

b. HEC-RAS input files for the riverine Probable Maximum Flood analysis (Section 3.2 of the Braidwood Flood Hazard Reevaluation Report (FHRR]).

Response: The requested HEC-RAS input files are provided in Enclosure 5, "Enclosure 1-(Braidwood)" folder under sub-folder "HEC-RAS" of the enclosed electronic files.

c. HEC-HMS input files for the riverine Probable Maximum Flood analysis (Section 3.2 of the Braidwood FHRR) and the cooling pond for the cooling pond (Section 3.3 of the Braidwood FHRR).

Response: The requested HEC-HMS input files are provided in Enclosure 5, "Enclosure 1-(Braidwood)" folder under sub-folder "HEC-HMS" of the enclosed electronic files.

Information provided in HEC-HMS folder under respective sub-folders labeled "Mazon and Kankakee" and "Cooling Pond" for riverine and cooling pond.

d. Excel spreadsheet associated with the Fast Fourier Transform used for wind storm events analysis (Section 3.3 of the FHRR).

Response: The requested Microsoft Excel file is provided in Enclosure 5, "Enclosure 1-(Braidwood)" folder file labelled "Spectral Analysis of Wind" of the enclosed electronic files.

e. Input files associated with the calibration and sensitivity simulations performed in HEC-RAS and HEC-HMS related to the riverine and cooling pond analyses in the report sections mentioned above.

Response: The flooding due to the LIP event and the cooling pond PMF were the controlling flood hazard mechanisms because they resulted in the highest water surface elevations close to the site. Therefore, sensitivity simulations (errors and uncertainties) were performed for the models associated with the Effects of LIP (FLO-2D) and Cooling Pond PMF (HEC-HMS) calculations.

The other flooding mechanisms resulted in lower water surface elevations compared to the controlling flood hazard. Therefore, sensitivity simulations for those mechanisms were not performed. Additionally no calibration was performed for Kankakee River and Cooling Pond.

Response to Request for Additional Information (Flood Hazard Reevaluation Report)

Page 2 of 2 The requested sensitivity simulations files are provided in Enclosure 5, "Enclosure 1-(Braidwood)" folder under sub-folder "Sensitivity (Error- Uncertainty)" of the enclosed electronic files. Information provided in Enclosure 5, "Enclosure 1-(Braidwood)" under respective sub-folders labeled "Cooling Pond Error-Uncertainty" for cooling pond PMF and "FLO-2D Error-Uncertainty" for Effects of LIP.

Enclosure 2 Byron Station, Units 1 and 2 Response to NRC Request for Additional Information Regarding FHRR (2 pages)

Response to Request for Additional Information (Flood Hazard Reevaluation Report)

Page 1 of 2 Byron Station

a. Input and output files associated with the FLO-2D modeling of Local Intense Precipitation. With regards to the output files, include any that provide depths, velocities, and water surface elevations (e.g.

SUMMARY

.out, DEPTH.out).

Response: The requested FLO-2D input and output files are provided in Enclosure 5, "Enclosure 2-(Byron)" folder under sub-folder "FLO-2D" of the enclosed electronic files.

Information provided in sub-folder labeled "LIP" within folder "FLO-2D".

b. HEC-HMS input files for the riverine Probable Maximum Flood analysis (Section 3.2 of the Flood Hazard Reevaluation Report [FHRR]), onsite basin failures analysis (Section 3.4 of the FHRR), and downstream ice jam analysis (Section 3.6 of the FHRR).

Response: The requested HEC-HMS input files are provided in Enclosure 5, "Enclosure 2-(Byron)" folder under sub-folder "HEC-HMS" of the enclosed electronic files. The information included in HEC-HMS folder is-

" Folder Byron_PMF Includes PMF runs

" Folder ByronUH Includes PMF runs with Non-linear unit hydrograph adjustment

" Folder CalibrationVerification Includes Calibration & Verification Files

" Folder On-SiteFailure Includes onsite failure analysis

" Folder DATA Includes Supporting Data and dss files Downstream ice jam analysis was performed using HEC-RAS model instead of HEC-HMS model. The HEC-RAS model provided as part of response to Item c includes both upstream and downstream ice jam analysis.

c. HEC-RAS input files for the riverine Probable Maximum Flood (Section 3.2 of the FHRR) and upstream dam failures (Section 3.4 of the FHRR).

Response: The requested HEC-RAS input files are provided in Enclosure 5, "Enclosure 2-(Byron)" folder under sub-folder "HEC-RAS" of the enclosed electronic files.

d. Input and output files for FLO-2D modeling for the onsite basin failures.

Response: The requested FLO-2D input and output files for onsite basins (NDCT Flume and UHS Basin) are provided in Enclosure 5, "Enclosure 2-(Byron)" folder under sub-folder "FLO-2D" of the enclosed electronic files. Information provided in sub-folders labeled "NDCT Failure" and "UHS Failure" within folder "FLO-2D".

e. Input files associated with calibration and sensitivity simulations performed using HEC-RAS and HEC-HMS related to the riverine and upstream dam failure.

Response: The flooding due to the LIP event was the controlling flood hazard mechanisms because it resulted in the highest water surface elevations closest to the site. Therefore, sensitivity simulations (errors and uncertainties) were performed for the model associated with the Effects of LIP (FLO-2D) analysis.

Response to Request for Additional Information (Flood Hazard Reevaluation Report)

Page 2 of 2 The other flooding mechanisms resulted in lower water surface elevations compared to the controlling flood hazard. Therefore, sensitivity simulations for those mechanisms were not performed. The calibration simulations performed using HEC-HMS and HEC-RAS are included in models included in response to Items "b" and "c" respectively.

The requested sensitivity simulations files are provided in Enclosure 5, "Enclosure 2-(Byron)" folder under sub-folder "Sensitivity (Error- Uncertainty)" of the enclosed electronic files.

Enclosure 3 Clinton Power Station, Unit 1 Response to NRC Request for Additional Information Regarding FHRR (2 pages)

Response to Request for Additional Information (Flood Hazard Reevaluation Report)

Page 1 of 2 Clinton Station

a. Input and output files associated with the FLO-2D modeling for the local intense precipitation event. This includes any output files that provide depths, velocities, and water surface elevations (e.g.,

SUMMARY

.out, DEPTH.out).

Response: The requested FLO-2D input and output files are provided in Enclosure 5, "Enclosure 3-(Clinton)" folder under sub-folder "FLO-2D" of the enclosed electronic files.

b. HEC-HMS input files for the Clinton Lake probable maximum flood analysis (Section 3.2 of the Flood Hazard Reevaluation Report [FHRR]).

Response The requested HEC-HMS input files are provided in Enclosure 5, "Enclosure 3-(Clinton)" folder under sub-folder "HEC-HMS Files" of the enclosed electronic files.

c. HEC-RAS input files for the Clinton Lake probable maximum flood analysis (Section 3.2 of the FHRR).

Response: The requested HEC-RAS input files are provided in Enclosure 5, "Enclosure 3-(Clinton)" folder under sub-folder "HEC-RAS Files" of the enclosed electronic files.

d. Delft3D input and output for the probable maximum storm surge and seiche for Clinton Lake (Section 3.3 of the FHRR).

Response: The requested Delft 3D input and output files are provided in Enclosure 5, "Enclosure 3-(Clinton)" folder under sub-folder "Delft 3D" of the enclosed electronic

e. Excel spreadsheet associated with the fast Fourier transform used for wind storm events analysis (Section 3.3 of the FHRR).

Response: The Fourier transformation is performed using R computer program. The files are provided in Enclosure 5, "Enclosure 3-(Clinton)" folder under sub-folder labeled "CON WIND outputs" within folder "Delft 3D".

f. Input files associated with calibration and sensitivity simulations performed using HEC-RAS and HEC-HMS related to the Clinton Lake analyses.

Response: The flooding due to the LIP event was the controlling flood hazard mechanism because it resulted in the highest water surface elevations closest to the site. Therefore, sensitivity simulations (errors and uncertainties) were performed for the model associated with the Effects of LIP (FLO-2D) analysis.

The other flooding mechanisms resulted in lower water surface elevations compared to the controlling flood hazard. Therefore, sensitivity simulations for those mechanisms were not performed. The calibration simulations performed using HEC-HMS and HEC-RAS are included in models included in response to Items "b" and "c" respectively.

Response to Request for Additional Information (Flood Hazard Reevaluation Report)

Page 2 of 2 The requested sensitivity simulations files are provided in Enclosure 5, "Enclosure 3-(Clinton)" folder under sub-folder "Sensitivity (Error- Uncertainty)" of the enclosed electronic files.

Enclosure 4 LaSalle County Station, Units 1 and 2 Response to NRC Request for Additional Information Regarding FHRR (2 pages)

Response to Request for Additional Information (Flood Hazard Reevaluation Report)

Page 1 of 2 LaSalle Station

a. Input and output files associated with the FLO-2D modeling for the local intense precipitation event. This includes any output files that provide depths, velocities, and water surface elevations (e.g.

SUMMARY

.out, DEPTH.out).

Response: The requested FLO-2D input and output files are provided in Enclosure 5, "Enclosure 4-(La Salle)" folder under sub-folder "FLO-2D" of the enclosed electronic files.

b. HEC-HMS input files for the cooling lake Probable Maximum Flood analysis (Section 3.2 of the Flood Hazard Reevaluation Report [FHRR]).

Response: The requested HEC-HMS input files are provided in Enclosure 5, "Enclosure 4-(La Salle)" folder under sub-folder "HEC-HMS" of the enclosed electronic files.

c. HEC-RAS input files for the cooling lake probable maximum flood analysis (Section 3.2 of the FHRR).

Response: The requested HEC-RAS input files are provided in Enclosure 5, "Enclosure 4-(La Salle)" folder under sub-folder "HEC-RAS" of the enclosed electronic files.

d. Delft3D input and output for the probable maximum storm surge and seiche for the cooling lake (Section 3.3 of the FHRR).

Response: The requested Delft 3D input and output files are provided in Enclosure 5, "Enclosure 4-(La Salle)" folder under sub-folder "Delft 3D" of the enclosed electronic files.

e. Excel spreadsheet associated with the fast Fourier transform used for wind storm events analysis (Section 3.3 of the FHRR).

Response: The requested Microsoft Excel file is provided in Enclosure 5, "Enclosure 4-(LaSalle)" folder file labelled "Spectral Analysis of Wind" of the enclosed electronic files.

f. Input files associated with calibration and sensitivity simulations performed using HEC-RAS and HEC-HMS related to the cooling lake analyses.

Response: The flooding due to the LIP event and the storm surge were controlling flood hazard mechanisms because they resulted in the highest water surface elevations close to the site. Therefore, sensitivity simulations (errors and uncertainties) were performed for the models associated with the Effects of LIP (FLO-2D) and storm surge (Delft 3D) calculations.

The other flooding mechanisms resulted in lower water surface elevations compared to the controlling flood hazard. Therefore, sensitivity simulations for those mechanisms were not performed. Additionally no calibration was performed.

Response to Request for Additional Information (Flood Hazard Reevaluation Report)

Page 2 of 2 The requested sensitivity simulations files are provided in Enclosure 5, "Enclosure 4-(LaSalle)" folder under sub-folder "Sensitivity (Error- Uncertainty)" of the enclosed electronic files. Information is provided under respective sub-folders labeled "DELFT-3D" for cooling lake and "FLO-2D Pro" for Effects of LIP.

Enclosure 5 Hard Drive with Electronic Information